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North Korean animation outsourcing for Amazon, HBO Max series

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Re: North Korean animation outsourcing for Amazon, HBO Max series

#35
The HN headline is more clickbaitey than the original article, which has a different headline and goes out if its way to point out that Amazon and HBO are likely not the ones doing the outsourcing to North Korea.

> There is no evidence to suggest that the companies identified in the images had any knowledge that a part of their project had been subcontracted to North Korean animators. In fact, as the editing comments on all the files, including those related to US-based animations, were written in Chinese, it is likely that the contracting arrangement was several steps downstream from the major producers.

Re: North Korean animation outsourcing for Amazon, HBO Max series

#36

Generally, how far downstream does the US State Department expect companies to vet vendors for sanctions violation? Due diligence this many layers deep is expensive, especially if hostile (investigative work to proactively discover dishonest sourcing reports.) I would think it would vary by industry--e.g. animation is obviously less stringent than medical devices so would have fewer reporting and certification struct…

The entire chain all the way down is sanctioned, the US can and will climb up and down that chain to punish sanctions violations. A company like Disney will have to have a Sanctions Compliance Program and like any other compliance regime, there are standards, external auditors, etc. to make sure enough is being done, and "enough" can be a bit of a moving target. If you get caught having sanctioned suppliers, those standards and auditing get kicked up a notch, if you did a really bad job maybe fines or criminal charges.

There isn't ever a sense of "I'm doing enough and therefore the sanctions violations happening are no longer my fault". It's somewhat up to you to determine your risk and tailor your compliance program to address them and to adjust if you're ever wrong.

How guilty you are is a function of how good a job the state department thinks you're doing trying to avoid sanctions violations.

Re: North Korean animation outsourcing for Amazon, HBO Max series

#38

Seems like a difficult problem to solve. It shows the importance of paying close attention. NK has shown to be quite good at bypassing sanctions but it seems that the link is almost always through China. It would seem that the best way to go about this would be through stricter negotiations with them, since they are already acting as a significant intermediary. Either they know about this or the great firewall is not…

@dang is a no-op. You should send an e-mail to hn@ycombinator.com. I'm writing one as I write this comment.
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